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`The Atlantic Building
`950 F Street, NW
`Washington, DC 20004-1404
`
`202-239-3300
`Fax: 202-239-3333
`www.alston.com
`
`Jamie D. Underwood
`
`Direct Dial: 202-239-3706
`
`Email: jamie.underwood@alston.com
`
`
`August 7, 2017
`
`VIA EDIS
`
`The Honorable Lisa R. Barton, Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
`
`
`
`
`Re: Certain Hybrid Electric Vehicles and Components Thereof,
`Inv. No. 337-TA-1042
`
`
`Dear Secretary Barton:
`
`On behalf of Respondent Ford Motor Company, enclosed for filing please find a
`subscription to the Amended Protective Order (Order No. 10) for Jennifer (Celine) Liu in
`the above-captioned investigation.
`
`
`Respectfully,
`
`/s/ Jamie D. Underwood
`
`Jamie D. Underwood
`
`
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`Enclosures
`
`Atlanta • Beijing • Brussels • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley • Washington, D.C.
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`
`The Atlantic Building
`950 F Street, NW
`Washington, DC 20004-1404
`
`202-239-3300
`Fax: 202-239-3333
`www.alston.com
`
`Jennifer (Celine) Liu
`
`Direct Dial: 202-239-3752
`
`Email: celine.liu@alston.com
`
`
`
`August 7, 2017
`
`
`The Honorable Lisa R. Barton, Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
`
`
`
`
`
`Re:
`
`Certain Hybrid Electric Vehicles and Components Thereof,
`Inv. No. 337-TA-1042
`
`
`Dear Secretary Barton:
`
` I
`
` am counsel for Respondent Ford Motor Company (“Ford”) in the above-referenced
`investigation. By this letter, I acknowledge that I have read the Amended Protective Order
`(Order No. 10) issued by Administrative Law Judge David P. Shaw in this investigation
`on May 22, 2017 (“Protective Order”), and hereby agree:
`
`(1)
`
`(2)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential information to anyone other than another person
`designated in Paragraph 3 of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for the purposes of this
`investigation, unless permission is received from the supplier, or the Administrative
`Law Judge, or the Commission to use it for other purposes.
`
`
`In addition, I, the undersigned, on behalf of Ford, acknowledge that information submitted
`for purposes of this investigation may be disclosed and used:
`
`
`(i)
`
`By the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the
`programs, personnel, and operations of the Commission including under 5
`U.S.C. Appendix 3; or
`
`
`Atlanta • Beijing • Brussels • Charlotte • Dallas • Los Angeles • New York • Research Triangle • Silicon Valley • Washington, D.C.
`
`
`
`(ii)
`
`By U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate
`nondisclosure agreements.
`
`
`Sincerely,
`
`/s/ Jennifer Liu
`
`Jennifer (Celine) Liu
`
`
`
`
`
`
`
`
`Certain Hybrid Electric Vehicles and Components Thereof
`
`Inv. No. 337-TA-1042
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that on this day, a true and correct copy of the foregoing document
`was served by the indicated means to the persons at the addresses below:
`
`Via Electronic Filing (EDIS)
`
`Via Hand Delivery (1 Copy)
`
`Via Electronic Mail to:
`Pyong.Yoon@usitc.gov
`
`Via Electronic Mail to:
`
`FRServPaice_1042@fr.com
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`The Honorable David P. Shaw
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW Room 317
`Washington, D.C. 20436
`
`Pyong Yoon
`Attorney Advisor
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`Counsel for Complainants Paice LLC
`and Abell Foundation, Inc.
`
`Ruffin B. Cordell
`Indranil Mukerji
`Ahmed J. Davis
`Ralph A. Phillips
`Thomas S. Fusco
`Brian J. Livedalen
`Daniel A. Tishman
`Laura C. Whitworth
`FISH & RICHARDSON P.C.
`901 15th Street, N.W. 7th Floor
`Wahsing ton
`Washington, D.C. 20005
`
`Washington, D.C. 20005
`
`John S. Goetz
`FISH & RICHARDSON P.C.
`153 East 53rd Street
`New York, NY 10022
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`Date: August 7, 2017
`
`
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`
`
`/s/ Desiree P. January
`
`Desiree P. January
`
`
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